Tracie Young - Page 16

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          would not suffer economic hardship if the Service did not grant             
          relief from the income tax liability; (5) petitioner had actual             
          knowledge that in 1995, Mr. Glaze worked for and received income            
          from Mayflower; and (6) petitioner had actual knowledge of the              
          $24 of interest income received jointly by petitioner and Mr.               
          Glaze from the United States Treasury.  Respondent asserts that             
          these factors weigh against granting relief to petitioner.  We              
          now address each of the factors of Rev. Proc. 2000-15, sec. 4.03,           
          separately.                                                                 
          1.  Marital Status                                                          
               During 1995, petitioner and Mr. Glaze were married and                 
          resided in the same household; however, Mr. Glaze was frequently            
          away from home driving a truck for Melton Truck Lines and                   
          Mayflower.  Petitioner and Mr. Glaze were divorced on May 26,               
          1999.  This factor weighs in favor of granting relief to                    
          petitioner.                                                                 
         2.  Economic Hardship                                                        
              Respondent contends that petitioner offered no evidence that            
         she would suffer economic hardship if relief were denied.                    
         Pursuant to section 301.6343-1(b)(4)(ii), Proced. & Admin. Regs.,            
         economic hardship exists if a levy will cause a taxpayer to be               
         unable to pay his/her reasonable basic living expenses.                      
         Respondent maintains that respondent’s collection activity would             







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